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CSSF Circular 25/894 and FAQ - Notification requirements for luxembourg investment fund managers managing non-authorised investment funds

31 July 2025

The Luxembourg financial regulator (Commission de Surveillance du Secteur Financier, or CSSF) has issued Circular 25/894 (the "Circular"), which repeals CSSF Circular 15/612 and sets out new requirements for Luxembourg investment fund managers (IFMs) when they manage investment funds that are not authorised by the CSSF. The Circular took effect on 27 June 2025 and aims to ensure that the CSSF has a comprehensive, up-to-date overview of all funds managed by Luxembourg IFMs, including those domiciled abroad or otherwise not authorised by the CSSF. The Circular's accompanying FAQ, which is currently only available in French, provides further clarifications on the practical application of the new requirements.

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